The Next Step – Consumer Support

The procedural request has been submitted, now it is time for pet owners to gather signatures telling AAFCO consumers support labeling changes requiring pet feed to be labeled as feed. Everyone’s help is needed.

Clearly label pet products as ‘Feed’ or ‘Food’; if the product meets the legal requirements of food it will be termed Cat Food or Dog Food on the label and in all marketing – if the product does not meet the legal requirements of food it will be termed Cat Feed or Dog Feed on the label and in all marketing.

Simple, easy to understand transparency for consumers.

Everything boils down to this one sentence of law (Federal Food Drug and Cosmetic Act):

In prescribing a definition and standard of identity for any food or class of food in which optional ingredients are permitted, the Secretary shall, for the purpose of promoting honesty and fair dealing in the interest of consumers, designate the optional ingredients which shall be named on the label.

Feed grade pet product ingredients ARE “optional ingredients” permitted by FDA and each State Department of Agriculture. “For the purpose of promoting honest and fair dealing in the interest of consumers”, these pet products must be declared as Cat Feed and/or Dog Feed on the label.

The procedural steps have been completed (FDA requested we submit the feed/food labeling issue as an addendum to our Citizen Petition filed October 2016). Here is the link to the Regulations.gov website (our addendum is the second item): https://www.regulations.gov/docket?D=FDA-2016-P-3578

In part – we submitted the following addendum:

Action Requested

(5) This petition requests the Commissioner to establish a standard of identity for pet food/treat products providing consumers clarification. Pet food/treat standard of identity would be a simple, easy to understand classification of ‘pet feed’ or ‘pet food’. Pet products that meet the requirements of “Human Grade” as defined by AAFCO would be termed “Pet Food” (Example: cat food, dog food). Pet products that do not meet the full requirement of Human Grade would be termed “Pet Feed” (Example: cat feed, dog feed) with the option for verified exception (a) below.

(a) Similar to the USDA grading of meat, this petition requests the Commissioner establish an optional fee-based pet product ingredient quality verification system; providing consumers a validated standard of identity to quality of ingredients even if the pet product was manufactured in a USDA or pet food facility (does not meet the full requirement of Human Grade pet food). Pet products that complete the verification process (verifying all human grade ingredients) would be provided opportunity to state on product labels and in marketing the claim ‘Verified Pet Food’ (or similar disclosure) providing consumers with another level of standard of identity.

Reverification would be required at any ingredient change or supplier change.

This petition requests the definition of ‘pet food’, ‘pet food verified’, and ‘pet feed’ become public information available on the FDA website.

This petition requests the Commissioner to promptly establish the above standard of identity for pet food products providing consumers with honest and fair information. Should participation from AAFCO (Association of American Feed Control Officials) be required, this petition requests the Commissioner to work with AAFCO to promptly facilitate this consumer transparency update.

Now the hard part…

FDA believes the fastest path to making this feed/food declaration of pet products is through the AAFCO process. FDA agreed to introduce the disclosure at the upcoming AAFCO meeting (beginning August 10, 2017).

Going ‘through the AAFCO process’ means…

FDA introduces the suggestion at the meeting in August 2017;

Industry will throw a hissy fit;

Because existing regulations within the AAFCO Official Publication will need to be changed, the existing Pet Food Labeling Modernization Working Group will (consisting of regulatory, consumer advocates and industry advocates) will write/update the necessary laws;

The new regulations developed by the Working Group will be discussed at a future AAFCO public meeting, more industry hissy fit, AAFCO members will vote to approve or deny the labeling updates.

We are requesting the schedule to follow this timeline…

Update all existing Model Regulations for Pet Food and Specialty Pet Food to include the feed/food/verified food distinction to be completed no later than the August 2018 Annual Meeting. Updated model regulations to be published in the 2019 AAFCO Official Publication.

Deadline for pet food manufacturer compliance no later than 1 year from publication of the 2019 Official Publication (deadline: January 2020).

Big Pet Feed has a loud voice at AAFCO, their complaints regarding required feed/food labeling will be listened to by AAFCO. Consumer voices need to be louder!

Although it would be wonderful if hundreds of thousands of consumers could attend an AAFCO meeting declaring their support for the feed/food required labeling, at $500 just to attend – that’s not going to happen. The next best thing – is hundreds of thousands of signatures on a petition telling AAFCO to swiftly move the feed/food required labeling through.

So many consumers ask me how can they help? This is how. Help get signatures on this petition.

Sign and share! Send the petition to every pet food consumer you know – Care2 makes it easy to share.

Signatures will be delivered to AAFCO at the August meeting (beginning 8/10/2017).

This change in pet food won’t happen easily – industry will battle us. But…with thousands – hundreds of thousands of signatures on this petition consumers will be a loud voice that AAFCO will need to listen to. Sign and share! Thank you in advance.

Susan, just a quick question – I live in Canada – does a Canadian signature count on this petition since this is to change US federal legislation and not Canadian. Your hard work is much appreciated. Thank you.

I am not sure how this would stop a company like Evanger’s. Will there be meaningful consequences to violations? How will they monitor for compliance? I can just picture the commercials trying to convince consumers that feed grade is just as good as human grade.

Right now the only way Evangers is going to be stopped, is through their own stupidity. Meaning, self-destruction, which is bankruptcy via settlements, publicity failure, or ignoring the FDA’s warning letter. But Evangers isn’t Susan’s job here although their mistake created (the unfortunate) opportunity to prove a point, which also made the “The Next Step” possible. Because now somebody is listening.

Really it’s all about the future. You’d have to know TAPF 10 years ago, to appreciate this phenomenal change! From JUST one word (feed) to another word (food) you’d ask? Absolutely! Because at last it forces manufacturers to defend feed grade! Or to provide food grade products. Do consumers want to give a diet equivalent to livestock feed, or provide optimal wholesome nutrition, increasing lifespan and well-being. Companies see their future already. It’s why they’ll fight this change. And why WE need thousands of signatures! Because it means a dynamic shift in how they’ll be FORCED to operate. So if Evangers does decide to label their product Pet Food, when it isn’t, then imagine how much easier …. it really will be the next time … to shut them down.

Please share with everyone how important the petition is. And don’t forget to follow up with people if they’ve promised to help. In the end, only the REAL number…. will count!!!

What the heck does that one sentence of law mean? While the words are English, the sentence as a whole is an entirely different language. This is why FDA, and other government bodies, gets to do whatever they want – because it takes an army of lawyers and a judge or two to interpret the law as seen fit by whoever has the most muscle money.

In reply to my own rant, followers and supporters should be very proud to know about 42,600 signatures finally posted and July 31 is the cut-off. This is an incredible achievement, because of how many people have now been informed about the issue! I’d like to see the expression on the faces of “industry” when this list is presented!!